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Governmental Auditing Updates

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Presentation by Jill Shaw and Brittney Williams at the Association of Local Government Auditors Phoenix Regional Training on 9/28/17

Published in: Government & Nonprofit
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Governmental Auditing Updates

  1. 1. Governmental Auditing Updates Jill A. Shaw, CPA Brittney Williams, CPA, CGFM
  2. 2. Agenda + surprise fun and games GASB Updates Uniform Guidance Developments Yellow Book AICPA 2
  3. 3. Statement No. 72: Fair Value Measurement and Application Statement No. 82: Pension Issues – An Amendment of GASB Statement No. 67, No. 68, and No. 73 (WITH EARLY IMPLEMENTATION) 3 GASBS in Review
  4. 4. GASB Statement No. 72 Fair Value Measurement and Application (periods beginning after June 15, 2015)  The statement addresses accounting and financial reporting issues related to fair value measurements; it defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. It also provides guidance for determining a fair value measurement for financial reporting and disclosure purposes Fair Value Level 3 Level 2 Level 1 4
  5. 5. GASB Statement No. 72 5 Quoted prices (unadjusted) in active markets for identical assets or liabilities Level 1 Quoted prices for similar assets or liabilities, quoted prices for identical assets or liabilities in markets that are not active, or other than quoted prices that are observable Level 2 Unobservable inputs Level 3
  6. 6. GASB Statement No. 72  Investments not measured at fair value include the following: • Money market investments • External investment pools (2a7-like) • Investments in life insurance contracts • Common stock meeting the criteria for the equity method • Unallocated insurance contracts • Synthetic guaranteed investment contracts  Additional note: a government is permitted in certain circumstances to establish the fair value of an investment that does not have a readily determinable fair value by using the net asset value per share (or its equivalent) of the investment 6
  7. 7. GASB Statement No. 82 Pension Issues – An Amendment of GASB Statement No. 67, No. 68, and No. 73 (periods beginning after June 15, 2016; periods beginning after June 15, 2017 for measurement dates after the employer’s most recent fiscal year)  The statement addresses the presentation of payroll-related amounts in the required supplementary information, the selection of assumptions and the treatment of deviations from the guidance in an Actuarial Standard of Practice for financial reporting purposes, and the classification of payments made by employers to satisfy employee (plan member) contribution requirements  Covered Payroll: the payroll on which contributions to a pension plan are based 7
  8. 8. GASBS Updates – Upcoming 8 Statement No. 73 (Pensions) FY16/FY17 Statement No. 74 (OPEB) FY17 Statement No. 75 (OPEB) FY18 Statement No. 77 (Tax Abatements) FY17 Statement No. 79 (Investment Pools) FY16/FY17 Statement No. 78 (Pensions) FY17 Statement No. 80 (Component Units) FY17 Statement No. 81 (Split-Interest Agreements) FY18 Statement No. 83 (Asset Retirement Obligations) FY19
  9. 9. GASBS Updates – are we done yet? 9 Statement No. 84 (Fiduciary Activities) FY20 Statement No. 85 (Omnibus) FY19 Statement No. 86 – Certain Debt Extinguishment Issues FY18 Statement No. 87 –Leases FY21 Other GASB Projects : Implementation Guide 2017-1 Issued, Reporting Model Re-examination
  10. 10. Statement No. 74/75: Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans / Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions Statement No. 77: Tax Abatement Disclosures 10 GASBS Updates
  11. 11. GASB Statement No. 74 Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans (periods beginning after June 15, 2016)  The statement replaces Statements No. 43 and 57; additionally, the statement also replaces requirements from Statements No. 25, 43, and 50  The scope of the statement includes OPEB plans (defined benefit and defined contribution) administered through trusts that meet the following criteria: • Contributions from employers and nonemployer contributing entities to the plan (and earnings on those contributions) are irrevocable • Plan assets are dedicated to providing benefits to plan members in accordance with the benefit terms • Plan assets are legally protected from the creditors of employers, nonemployer contributing entities, and the plan administrator. If the plan is a defined benefit plan, plan assets also are legally protected from creditors of the plan members  The statement also includes OPEB plans (defined benefit and defined contribution) not administered through trusts and defined contribution OPEB plans administered through trusts 11
  12. 12. GASB Statement No. 75 Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (periods beginning after June 15, 2017)  The statement replaces Statements No. 43 and 57  The scope of the statement includes OPEB plans (defined benefit and defined contribution) administered through trusts that meet the following criteria: • Contributions from employers and nonemployer contributing entities to the plan (and earnings on those contributions) are irrevocable • Plan assets are dedicated to providing benefits to plan members in accordance with the benefit terms • Plan assets are legally protected from the creditors of employers, nonemployer contributing entities, the plan administrator, and the plan member  The statement also includes OPEB plans (defined benefit and defined contribution) not administered through trusts and defined contribution OPEB plans administered through trusts 12
  13. 13. GASB Statement Nos. 74/75  When are these statements effective? • Statement No. 74 is effective for OPEB plans (ex. ASRS – health insurance benefit) for fiscal year’s beginning after June 15, 2016 • Statement No. 75 is effective for OPEB employers (ex. employers – school districts) for fiscal year’s beginning after June 15, 2017  Are these statements similar to the pension statements (Statements Nos. 67/68), but for OPEB? • Yes • Employer governments participating in OPEB plans will be reporting their respective net OPEB liability, as well as related deferred outflows of resources and deferred inflows of resources • Required notes to the financial statements and required supplementary information are significant • Governmental fund financial statements are not directly affected 13
  14. 14. GASB Statement Nos. 74/75 14
  15. 15. GASB Statement Nos. 74/75  What is the difference between a plan administered by a trust and a plan not administered by a trust? • Contributions from employers and nonemployer contributing entities (and earnings on those contributions) are irrevocable in a Trust • Plan assets are dedicated to providing benefits to plan members in accordance with the benefit terms in a Trust • Plan assets are legally protected from the creditors of employers, nonemployer contributing entities, the plan administrator, and the plan member in a Trust  Is GASB Statement Nos. 74/75 applicable to OPEB plans not administered through a Trust? • Yes  What do I need to do for GASB Statement Nos. 74/75? • Ensure your actuary is aware of the additional/new valuation requirements for GASB Statement Nos. 74/75 • Ensure you receive a valuation that can be used for your FY18 financial statements 15
  16. 16. GASB Statement Nos. 74/75  Actuarial valuation of total OPEB liability • Project benefit payments  Based on claims costs (or age-adjusted premiums approximating claims costs)  Evaluation of benefit terms (through plan documents and discussions)  Consideration of legal or contractual caps on benefit payment  Incorporate the effect of projected salary changes and service credits (if applicable)  Incorporate the effect of automatic postemployment benefit changes (including COLA)  Include taxes or other assessments expected to be imposed on benefit payments • Discounted projected benefit payments (to actuarial present value)  Using a single discount rate that reflects the long-term expect rate of return (or a tax-exempt, high quality municipal bond rate, if certain conditions are not met) • Actuarial present value attributed to periods of plan members service  Using entry age (cost method) and level percentage of pay (periods service cost) 16
  17. 17. GASB Statement Nos. 74/75  Measurement of the net OPEB liability • Total OPEB liability less the OPEB plan’s fiduciary net position • Total OPEB liability valuation requires the use of an actuary; except, if a plan has fewer than 100 members (active and inactive) – an alternative measurement calculation is available • Actuarial valuation or calculation is required every two years (every year is encouraged) • The valuation or calculation date of the total OPEB liability cannot be more than 30 months and 1 day earlier than the employer’s current fiscal year-end; if the valuation is not performed on the measurement date, the valuation will need to be rolled-forward to the measurement date • The measurement date of the net OPEB liability cannot be more than 12 months earlier than the employer’s current fiscal year -end • All assumptions for the determination of the total OPEB liability are generally required to be in conformity with the guidance in the Actuarial Standards of Practice 17
  18. 18. GASB Statement Nos. 74/75 Valuation Date • No more than 30 months and 1 day before the employer’s current fiscal year-end Measurement Date • No more than 12 months before the employer’s current fiscal year-end Reporting Date • Current fiscal year- end 18
  19. 19. GASB Statement No. 75 Notes to Financial Statements Single/Agent Employer Cost-Sharing Employer OPEB Plan Description   Information About the Net OPEB Liability:   -Assumptions and Other Inputs   -OPEB Plan’s Fiduciary Net Position   -Changes in the Net OPEB Liability  -Proportionate Share of Collective Net OPEB Liability  19
  20. 20. GASB Statement No. 75 Required Supplementary Information Single/Agent Employer Cost-Sharing Employer Schedule of Changes in Net OPEB Liability and Related Ratios  Schedule of Contributions   Schedule of Proportionate Share of the Net OPEB Liability  20
  21. 21. GASB Statement Nos. 74/75  What happens if there is not a trust (or the related requirements are not met)? • For OPEB plans  Accumulated assets for OPEB purposes are required to be reported as assets of the employer (or nonemployer contributing entity)  If the assets are held in a fiduciary capacity, then they are required to be report in an agency fund  Assets in excess of liabilities for benefits due to plan members, as well as accrued investment and administrative expense, is required to be reported as a liability to the participating employers (or nonemployer contributing entity) • For OPEB employers  For defined benefit OPEB plans (other than insured benefits), an approach similar to plans with a trust related to measurement of OPEB liabilities, OPEB expense, and deferred inflows and outflows of resources is required; additionally, similar note disclosures and required supplementary information is required. However, no OPEB plan assets are incorporated  For insured benefits (through a defined benefit OPEB plan), expenses/expenditures are recognized in the amount equal to premiums or other payments; additionally, a brief description of the benefits provided is required 21
  22. 22. GASB Statement No. 75 What about defined contribution OPEB plans? • For defined contribution OPEB plans, OPEB expense is recognized for the amount of contributions or credits to employees’ accounts, net of forfeited amounts; a change in OPEB liability is recognized as the difference between OPEB expense and amounts paid. • Additionally, a plan description (similar to that of defined benefit plans), the amount of OPEB expense, the amount of forfeitures reflected in OPEB expense, and the amount of the employer’s liability is required for the notes to financial statements; no required supplementary information is required. 22
  23. 23. GASB Statement No. 75 Overall Impact  Financial Statements • Possible decrease in net position • Possible negative unrestricted net position  Notes and RSI Disclosures • Significant increase in additional information and schedules  Additional Questions • What is all this? • Requirement to accumulate resources to fund the net OPEB liability • Impact on bond and credit ratings  Resources • GASB – standards, implementation guides • Arizona Auditor General • State OPEB plan website • OPEB plan management and actuary report 23
  24. 24. GASB Statement No. 77 24 Agreement in Place Tax Abated Economic Development
  25. 25. GASB Statement No. 77 Tax Abatement Disclosures (periods beginning after December 15, 2016)  The statement requires governments that entered into tax abatement agreements to disclose the following information about the agreements • Brief descriptive information, such as the tax being abated, the authority under which tax abatements are provided, eligibility criteria, the mechanism by which taxes are abated, provisions for recapturing abated taxes, and the types of commitments made by tax abatement receipts • The gross dollar amount of taxes abated during the period • Commitments made by the government, other than to abate taxes, as part of a tax abatement agreement  Additionally, the disclosures should be organized by major tax abatement program and may disclose information for individual tax abatement agreements within those programs 25
  26. 26. GASB Statement No. 77 Brief Descriptive Information Gov’t’s Own Abatements Other Gov’t’s Abatements Name of government  Tax being abated   Name of program  Purpose of program  Authority to abate taxes  Eligibility criteria  Abatement mechanism  Recapture provisions  Types of recipient commitments  26 Other Disclosures Gov’t’s Own Abatements Other Gov’t’s Abatements Dollar amount of taxes abated   Amounts received or receivable from other governments associated with abated taxes   Other commitments by the government  Quantitative threshold for individual disclosure   Information omitted due to legal prohibitions  
  27. 27. Blending Requirements for Component Units GASB Statement No. 80  The statement amends the blending requirements for the financial statement presentation of component units of all state and local governments. The additional criterion requires blending of a component unit incorporated as a not-for-profit corporation in which the primary government is the sole corporate member. The additional criterion does not apply to component units included in the financial reporting entity pursuant to the provisions of Statement No. 39  Effective fiscal year 2017 27
  28. 28. Irrevocable Split-Interest Agreements GASB Statement No. 81  The statement requires that a government that receives funds through an irrevocable split-interest agreement recognize related assets, liabilities, and deferred inflows of resources at the inception of the agreement. Additionally, the statement requires that revenues are recognized when the resources become applicable to the reporting period  The statement also requires that a government recognize assets representing its beneficial interest in irrevocable split-interest agreement when they are administered by a third party (if the government controls the present service capacity of the beneficial interests  Effective for fiscal year 2018 28
  29. 29. Fiduciary Activities GASB Statement No. 84  The term “Custodial Funds” will replace “Agency Funds”  All fiduciary funds to be reported in the Statement of Changes in Fiduciary Net Position  Any administrative or direct financial involvement of the assets will result in the reporting of the activity as a governmental fund (or business-type activity) • Administrative or direct financial involvement includes maintaining checkbook, reconciliation of account, expenditure compliance determination, etc. • I.e. most all student activities funds will now be reported as a governmental fund 29
  30. 30. 30
  31. 31. Fiduciary Activities GASB Statement No. 84  Pension trust funds • Used to report pension and OPEB plans that are administered through trusts  Investment trust funds • Used to report fiduciary activities form the external portion of investment pools and individual investment accounts that are held in trust  Private-purpose trust funds • Used to report all fiduciary activities that are not required to be reported in pension trust or investment trust funds  Custodial funds • Other fiduciary activities that are not reported in another category  Effective for fiscal year 2020, earlier application is encouraged 31
  32. 32. 32
  33. 33. Lease Accounting GASB Statement No. 87 Will effectively eliminate the distinction between capital and operating leases Leases will create a new intangible asset Leases with terms less than 12 months will recognize expenses based on contract terms FASB and international standards have made similar changes Final pronouncement issued in June 2017. Effective for FY21 33
  34. 34. Lease Accounting 34
  35. 35. Financial Reporting Model Improvements Invitation to Comment Three proposed approaches: • Near-term approach – focus on activity within 90 days of year-end • Short-term approach – focus on activity with 12 months of year-end • Long-term approach – effectively accrual accounting that excludes capital assets and capital-related debt 35
  36. 36. Financial Reporting Model Improvements Invitation to Comment – Near-Term Approach  Most similar to current model- excludes items of a long-term nature  Normally would include recognition of items 60-90 days from end of the reporting period  Potential Benefits: • Would report amounts available for spending, conceptually similar to modified accrual • Similar to cash flow information, so statement of cash flows wouldn’t be necessary  Challenges: • Potential for inconsistencies still exist • Amounts available for spending will be overstated and perhaps misleading to users of the financial statements 36
  37. 37. Financial Reporting Model Improvements Invitation to Comment – Short-Term Approach Focus is on one-year fiscal period (operating cycle) Potential Benefits: • Would recognize all of the obligations that are payable and normally due within the next cycle and the resources available in that same cycle • Better basis for inter-period equity and align with the budgetary cycle Challenges: • Additional efforts in preparing and auditing • More estimations and assumptions for liabilities • Statement of cash flows would be required, additional preparation and audit costs 37
  38. 38. Financial Reporting Model Improvements Invitation to Comment – Long-Term Approach  Would recognize the transactions when they take place, regardless of when cash is received or paid, i.e. accrual basis  Does not recognize capital assets or capital-related debt  Potential Benefits: • Conceptually consistent recognition principles • Better basis for assessing inter-period equity • Few differences from the government-wide statements  Challenges: • Inconsistency in treatment of capital assets and capital-related debt differently from other assets and liabilities. • Statement of cash flows would be required, additional preparation and audit costs 38
  39. 39. Financial Reporting Model Improvements Invitation to Comment All three would exclude capital assets and capital- related debt All three approaches would require a same-page reconciliation to the government-wide statements Short-term and long-term approaches would likely require a statement of cash flows Budgetary comparison to original budget may be required 39
  40. 40. Financial Reporting Model Improvements Invitation to Comment Different views on the definition of financial resources – considerations given to removing prepaid items and inventory from the balance sheet Proposed changes to the existing format of the governmental fund financial statements Possible changes to the four categories for the statement of cash flows Comments on ITC due March 31, 2017 Estimated timeline 2020/2021 40
  41. 41. Items in Pre-Agenda Research Conduit Debt Going Concern Disclosures Note Disclosure Reexamination Social Impact Bonds Information Technology Agreements- Including Cloud Computing Major Project Revenue Recognition 41
  42. 42. Uniform Guidance Update 42
  43. 43. Audit Findings Increases the threshold for reporting known and likely questioned costs from $10,000 to $25,000 Requires identification of whether audit finding is a repeat from the immediately prior audit and if so the prior year audit finding number Provides that audit finding numbers be in the format prescribed by the data collection form, i.e. 2017-001 Status of prior year “Yellow Book” findings now required 43
  44. 44. Small Purchases Procurements Small purchases are procurements using Federal funds between $3,000 and $150,000 Federal guidelines do require competitive procurement methods Intended to be relatively simple and informal Quotations required from more than one source Sources may be online search, public websites, phone quotation, etc. 44
  45. 45. Other Procurement Considerations Must maintain written standards of conduct covering conflicts of interest with respect to employees engaged in the selection, award, and administration of contracts, including disciplinary actions for violations Definition of supplies revised to include computer equipment with an acquisition cost of less than $5,000 Contracting with small and minority business, women’s business enterprises and labor surplus area firms 45
  46. 46. Post Federal Award Requirements – Subrecipient Monitoring All pass-through entities must: • Ensure every subaward includes the thirteen required data elements listed in §200.338 • Evaluate each subrecipient’s risk of noncompliance • Consider imposing additional award conditions • Monitor the activities of the subrecipient • Provide training, assistance and on-site review if deemed necessary • Verify that a Single Audit is performed if required • Consider taking enforcement action for noncompliance 46
  47. 47. Frequently Asked Questions-FY 2017  Indirect Costs versus Administrative Costs  Grace period for updating Procurement Standards • Non-federal entity- 7/1/17 • Subrecipient risk assessment, findings  Organizing the content of the SEFA • Alternative state methods • Subtotals by agency • Program clusters  Auditee Responsibility • Summary of significant prior audit findings • Corrective action plan https://cfo.gov/wp-content/uploads/2017/08/July2017- UniformGuidanceFrequentlyAskedQuestions.pdf 47
  48. 48. SEFA Face of the SEFA must include - •Noncash assistance •Loan programs, including outstanding balances •Loan guarantee programs •Clusters 48
  49. 49. New Federal CFDA Schematic Scheduled effective date of October 1, 2018 Numbering construct will change from ##.### to ###.#### Prefix to align with the 3-digit agency code listed in the Treasury Account Symbol chart of accounts Examples • Dept. of Education: 091.0910 • Dept. of Transportation: 069.0205 • Dept. of Housing: 070.0872 49
  50. 50. Yellow Book Refresher and Update 50
  51. 51. When Does the Yellow Book Apply?  When required (i.e. law, regulation, contract) • HUD Audit Guide, US Dept. of Education Audit Guide • Increased application to For-Profit entities  Usually participation in federal programs (i.e. single audit)  Most governmental performance audits  Voluntary election by the auditee  Updated revision of Yellow Book expected to be released as an exposure draft in next month 51
  52. 52. Additional Yellow Book Requirements  Additional audit report • Internal control over financial reporting • Report on compliance  Additional independence documentation  Auditor competence and CPE  Additional considerations for material noncompliance  Considerations for abuse of funds 52
  53. 53. 53
  54. 54. Yellow Book Findings Format  Elements of the finding • Criteria – what should we have seen? • Condition – what did we see? • Cause – why did we see what we saw? • Effect – what is the result of what we saw?  Views of responsible officials  Recommendations  Status for prior year Yellow Book findings now required for Single Audits 54
  55. 55. Yellow Book Revision Major changes • New format to differentiate requirements from application guidance • Independence • Specialists • Continuing Professional Education (CPE) • Peer review • New financial audit requirements for waste 55
  56. 56. AICPA Code of Professional Conduct 56
  57. 57. Revised Code of Professional Conduct  Two New Conceptual Frameworks  Structure • Preface • Part 1: Members in public practice (includes independence) • Part 2: Members in business • Part 3: All Other Members  New Numbering Format • Appendix D to Code is a mapping document to the prior code citations 57
  58. 58. Code of Conduct - Members in Business  Prohibits a member from knowingly misrepresenting facts or subordinating his or her judgment  Requires a member to be candid and not knowingly misrepresent facts when dealing with an external accountant  Requires a member to have the knowledge required to perform duties and perform additional research or seek consultation when needed  Requires a member to correct an entity’s financial statements that are materially false or misleading  Requires a member to comply with regulations regarding the timely filing of personal tax returns  Must maintain confidentially of employer’s records and may not use confidential information as a result of prior employment to his or her personal advantage or advantage of a third party, such as a prospective employer 58
  59. 59. Conflicts of Interest (COI)  Examples of Conflict of Interest for Members in Business • Serving in a management or governance position for two employing organizations and acquiring confidential information from one employing organization that could be used by the member to the advantage or disadvantage of the other employing organization • Being responsible for selecting a vendor for the member’s employing organization when the member or his or her immediate family member could benefit financially from the transaction • Serving in a governance capacity or influencing an employing organization that is approving certain investments for the company in which one of those specific investments will increase the value of the personal investment portfolio of the member or his or her immediate family member  Steps outlined for addressing conflicts of interest  Identify COI, Evaluate COI, Disclose/Obtain Consent 59
  60. 60.  Online Platform • Basic and Advanced Search Capability • Pop-ups • Bookmarks • Record Notes • Hyperlinking  Available at aicpa.org Online Code of Professional Conduct 60
  61. 61. Statement on Auditing Standards SAS 130 Audit of Internal Control Over Financial Reporting Integrated with Audit of Financial Statements • Applies when auditor is required to examine and report on effectiveness of internal control over financial reporting • Effective for integrated audits for periods ending on or after December 15, 2016 SAS 132 The Auditor’s Consideration of the Entity’s Ability to Continue as a Going Concern • Effective for periods ending on or after December 15, 2017 61
  62. 62. Statement on Auditing Standards • SAS 133, Auditor Involvement with Exempt Offering Documents  Effective for offering documents that are initially distributed, circulated or submitted on or after June 15, 2018.  Exempt offerings include: municipal securities, ST commercial paper, private placement offering  Auditor Involvement-BOTH must be present  Audit Report is included in the offering  Auditor performs one or more “triggering events” • Assist in preparing the information in the offering document • Provide written or oral comments in the offering document • Act of reading through the offering document at the client’s request • Issuing a Comfort Letter • Participating in due diligence conversations with the underwriters/brokers • others 62
  63. 63. On the Horizon Cybersecurity Assurance OPEB Implementation Financial Reporting Model “Big Data” testing by Auditors 63
  64. 64. Resources GASB • http://gasb.org/  Implementation Guide ED for OPEB  Financial Reporting Model ED AICPA • http://pub.aicpa.org/codeofco nduct/Ethics.aspx# Uniform Guidance • https://www.ecfr.gov/cgi- bin/text- idx?node=2:1.1.2.2.1&rgn=di v5 GAO- 2017 Yellow Book Exposure Draft • http://www.gao.gov/assets/69 0/683933.pdf Green Book • http://www.gao.gov/assets/67 0/665712.pdf 64

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